S.B. and U.S. Postal Service, Harrisburg Post Office (Board decision, May 29, 2026)

ECAB final decision. The Board affirmed OWCP's January 8, 2026 denial of the claim. A party may petition the Board for reconsideration within 30 days of issuance unless this order specifies another period, under 20 C.F.R. § 501.7(a). FECA compensation decisions are generally not subject to court review under 5 U.S.C. § 8128(b).

Plain-English summary

A postal worker sought FECA benefits for a condition she attributed to an accepted October 8, 2025 work incident. The Board found that her physician diagnosed left arm conditions but did not explain how the accepted incident caused them. It affirmed OWCP's denial because the medical record did not establish the required causal connection.

Decision snapshot

• Authority: Federal Employees' Compensation Act, 5 U.S.C. § 8101 et seq.; 20 C.F.R. §§ 501.2(c), 501.3.
• Outcome: OWCP's denial of the injury claim was affirmed.
• Key point: A diagnosis and an unsupported statement about work activity did not establish medical causation.

Full text (ECAB public release)

United States Department of Labor
Employees’ Compensation Appeals Board

________
)
S.B., Appellant
)
)
and ) Docket No. 26-0330
) Issued: May 29, 2026
U.S. POSTAL SERVICE, HARRISBURG POST
)
OFFICE, Harrisburg, PA, Employer
)
__________ )

Appearances: Case Submitted on the Record
Appellant, pro se
Office of Solicitor, for the Director

DECISION AND ORDER

Before:
PATRICIA H. FITZGERALD, Deputy Chief Judge JANICE B. ASKIN, Judge
VALERIE D. EVANS-HARRELL, Alternate Judge

JURISDICTION

On February 24, 2026 appellant filed a timely appeal from a January 8, 2026 merit decision of the Office of Workers’ Compensation Programs (OWCP). Pursuant to the Federal Employees’ Compensation Act1 (FECA) and 20 C.F.R. §§ 501.2(c) and 501.3, the Board has jurisdiction over the merits of this case.2

ISSUE

The issue is whether appellant has met her burden of proof to establish a medical condition causally related to the accepted October 8, 2025 employment incident.

1
5 U.S.C. § 8101 et seq.
2
The Board notes that, following the January 8, 2026 decision, appellant submitted additional evidence to OWCP and the Board. However, the Board’s Rules of Procedure provides: “The Board’s review of a case is limited to the evidence in the case record that was before OWCP at the time of its final decision. Evidence not before OWCP will not be considered by the Board for the first time on appeal.” 20 C.F.R. § 501.2(c)(1). Thus, the Board is precluded from reviewing this additional evidence for the first time on appeal. Id.
FACTUAL HISTORY

On October 21, 2025 appellant, then a 51-year-old postal distribution clerk, filed a traumatic injury claim (Form CA-1) alleging that on October 8, 2025 she injured her left elbow while in the performance of duty. She explained that she developed “golfer’s elbow after repeatedly lifting mail.” On the reverse side of the claim form, N.W., appellant’s supervisor, contended that appellant did not use the proper technique for picking up mail. Appellant stopped work on October 8, 2025, and returned to full-time modified-duty work on November 24, 2025.

In an October 14, 2025 report, Dr. Andrew Maul, a Board-certified internist, found that appellant was totally disabled from work commencing October 8, 2025. He determined that she could return to light-duty work on October 22, 2025. In a treatment note of even date, Dr. Maul diagnosed left forearm strain, left elbow pain, and golfer’s elbow of the left upper extremity. He opined that appellant had developed left golfer’s elbow from repetitive motion at work, specifically lifting mail.

In an October 28, 2025 development letter, OWCP informed appellant of the deficiencies of her claim. It advised her of the type of factual and medical evidence needed to establish her claim and provided a questionnaire for her completion. OWCP afforded appellant 60 days to submit the necessary evidence. In a separate development letter of even date, it requested that the employing establishment provide additional information regarding its allegation of improper lifting. OWCP afforded 30 days for a response.

OWCP subsequently received October 8, 20025 treatment notes from Samantha Carpenter, a physician assistant. Commencing October 28, 2025 appellant received treatment from Anthony Michael Lovat and Danie Burkhard, occupational therapists.

In a follow-up letter dated December 8, 2025, OWCP advised appellant that it had conducted an interim review, and the evidence submitted remained insufficient to establish her claim. It noted that she had 60 days from the October 28, 2025 letter to submit the necessary evidence. OWCP further advised that if the evidence was not received during this time, it would issue a decision based on the evidence contained in the record.

On December 9, 2025 the employing establishment controverted the claim, asserting that appellant had not submitted the medical evidence necessary to establish her claim.

On November 18, 2025 appellant completed the development questionnaire and attributed her condition to repetitive motions of lifting trays of mail “every day eight hours a day.” She then clarified that she believed her claim was for a traumatic injury occurring over one work shift.

In a December 16, 2025 note, a health provider with an illegible signature, released appellant to return to full-duty work without restrictions on January 16, 2025.

By decision dated January 8, 2026, OWCP denied appellant’s claim, finding that the medical evidence of record was insufficient to establish causal relationship between appellant’s diagnosed condition(s) and the accepted October 8, 2025 employment incident.

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LEGAL PRECEDENT

An employee seeking benefits under FECA3 has the burden of proof to establish the essential elements of his or her claim including the fact that the individual is an employee of the United States within the meaning of FECA, that the claim was timely filed, that an injury was sustained in the performance of duty, as alleged, and that any disability or medical condition for which compensation is claimed is causally related to the employment injury.4 These are the essential elements of every compensation claim regardless of whether the claim is predicated on a traumatic injury or an occupational disease.5

To determine whether a federal employee has sustained a traumatic injury in the performance of duty, it first must be determined whether fact of injury has been established. There are two components involved in establishing fact of injury. First, the employee must submit sufficient evidence to establish that he or she actually experienced the employment incident at the time and place, and in the manner alleged. Second, the employee must submit sufficient evidence to establish that the employment incident caused an injury.6

The medical evidence required to establish causal relationship between a claimed specific condition and an employment incident is rationalized medical opinion evidence. 7 The opinion of the physician must be based on a complete factual and medical background of the employee, must be one of reasonable medical certainty, and must be supported by medical rationale explaining the nature of the relationship between the diagnosed condition and the specific employment incident identified by the claimant.8

ANALYSIS

The Board finds that appellant has not met her burden of proof to establish a medical condition causally related to the accepted October 8, 2025 employment incident.

In an October 14, 2025 note, Dr. Maul diagnosed left forearm strain, left elbow pain, and golfer’s elbow of the left upper extremity. He opined that appellant had developed left golfer’s elbow from repetitive motion at work, specifically lifting mail. However, Dr. Maul failed to provide rationale for his conclusory opinion. The Board has held that medical evidence that does not offer a rationalized explanation by the physician of how the accepted employment incident

3
Supra note 1.
4
L.H., Docket No. 26-0201 (issued April 6, 2026); C.G., Docket No. 20-0058 (issued September 30, 2021); S.B., Docket No. 17-1779 (issued February 7, 2018); J.P., 59 ECAB 178 (2007); Joe D. Cameron, 41 ECAB 153 (1989). 5 J.M., Docket No. 17-0284 (issued February 7, 2018); R.C., 59 ECAB 427 (2008); James E. Chadden, Sr., 40 ECAB 312 (1988).
6
T.H., Docket No. 19-0599 (issued January 28, 2020); K.L., Docket No. 18-1029 (issued January 9, 2019);
John J. Carlone, 41 ECAB 354 (1989).
7
S.S., Docket No. 19-0688 (issued January 24, 2020); A.M., Docket No. 18-1748 (issued April 24, 2019);
Robert G. Morris, 48 ECAB 238 (1996).
8
A.S., Docket No. 19-1955 (issued April 9, 2020); Leslie C. Moore, 52 ECAB 132 (2000).

3 physiologically caused or aggravated the diagnosed condition(s) is of limited probative value.9 This evidence is therefore insufficient to establish the claim.

Appellant also submitted physician assistant and occupational therapist reports.
However, certain healthcare providers such as physician assistants and occupational therapists are not considered physicians as defined under FECA, and their reports do not constitute competent medical evidence.10 Consequently, their medical findings and/or opinions will not suffice for purposes of establishing entitlement to compensation benefits.11

As the medical evidence of record is insufficient to establish a medical condition causally related to the accepted October 8, 2025 employment incident, the Board finds that appellant has not met her burden of proof.

Appellant may submit new evidence or argument with a written request for reconsideration to OWCP within one year of this merit decision, pursuant to 5 U.S.C. § 8128 and 20 C.F.R. §§ 10.605 through 10.607.

CONCLUSION

The Board finds that appellant has not met her burden of proof to establish a medical condition causally related to the accepted October 8, 2025 employment incident.

9
S.E., Docket No. 26-0036 (issued January 29, 2026); S.B., Docket No. 26-0124 (issued March 4, 2026); D.D., Docket No. 25-0751 (issued August 27, 2025); T.L., Docket No. 23-0073 (issued January 9, 2023); V.D., Docket No. 20-0884 (issued February 12, 2021); Y.D., Docket No. 16-1896 (issued February 10, 2017). 10 Section 8102(2) of FECA provides as follows: physician includes surgeons, podiatrists, dentists, clinical psychologists, optometrists, chiropractors, and osteopathic practitioners within the scope of their practice as defined by State law. 5 U.S.C. § 8102(2); 20 C.F.R. § 10.5(t). See Federal (FECA) Procedure Manual, Part 2 -- Claims, Causal Relationship, Chapter 2.805.3a(1) (May 2023); David P. Sawchuk, 57 ECAB 316, 320 n.11 (2006) (lay individuals such as physician assistants, nurses, and physical therapists are not competent to render a medical opinion under FECA); see also F.A., Docket No. 24-0014 (issued January 30, 2026) (physician assistants are not considered physicians as defined by FECA); J.R., Docket No. 19-0812 (issued September 29, 2020) (an occupational therapist is not considered a physician under FECA). 11 Id.

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ORDER

IT IS HEREBY ORDERED THAT the January 8, 2026 decision of the Office of Workers’ Compensation Programs is affirmed.

Issued: May 29, 2026
Washington, DC

Patricia H. Fitzgerald, Deputy Chief Judge Employees’ Compensation Appeals Board

Janice B. Askin, Judge
Employees’ Compensation Appeals Board

Valerie D. Evans-Harrell, Alternate Judge Employees’ Compensation Appeals Board

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